[ID] => 10111
[post_author] => 43
[post_date] => 2018-09-18 07:54:34
[post_date_gmt] => 2018-09-18 06:54:34
[post_content] => I’ve really liked some of the people that I’ve shared a department or group with. In fact, usually, most of them. One year, a person that I’m still friends with today, had a milestone birthday. So I organized an at work celebration a bit more elaborate than the usual and, although we didn’t usually exchange gifts, I helped everyone pick out some inexpensive personalized or gag gifts. Everything went great. The customized birthday cake had just the right words and image, the gifts were laughed at by the group yet appreciated by the recipient, and every one seemed to have a good time.
The next day I needed to interact with a different co-worker, also one that is still my friend today, but she seemed a little aloof. After asking what was wrong and receiving a toneless “nothing” in response, I pushed harder. It turns out this friend had had a milestone birthday several weeks earlier, but nobody even mentioned it. I hadn’t even known it was her birthday and, if I had, I’d’ve done the same things I did for the first co-worker. But intent aside, the elaborate birthday celebration for one person had hurt another person’s feelings. As I said, we’re still friends even though I had hurt her feelings. And I’m glad she’s forgiven me. But I haven’t forgotten that even well-intentioned ideas can sometimes have unintended consequences.
A really good DG idea is to make hazard communication as language-independent as possible. Obviously, the symbols on labels, placards, and some marks help make written language unnecessary. The guy with the giant hand makes clear to me that I can’t put a package with an orange rectangle on any airplane that isn’t Cargo Aircraft Only, and the skull-and-crossbones lets me know of likely health issues if exposed to a 6.1 or 2.3 chemical. But what do we do about some hazard communication that must be in words, in particular, Proper Shipping Names (PSNs)?
“Bromine” in English is “Bromo” in Spanish. The British (not English) spelling of aluminum is “aluminium”, and so on. Well, you might think that’s an easy question, easily answered. We use four-digit identification numbers, (usually, but not always starting UN), and give each different PSN its own unique number. This approach has worked well for decades, and continues to work well today. Certainly, those involved with electronic data storage and communication love the idea of transmitting or entering only four characters and being able to retrieve much longer PSNs.
However, in today’s world of global shipping, where DG info is transferred to, from, and among various carriers in various modes, consolidators, freight forwarders, shippers, handling agents, temporary storage facilities, warehouses, ports, contract packers, and others, problems using only the identification numbers instead of the PSNs are cropping up occasionally. I’ll give some examples, but first I want to remind you that DG regulations sometimes require us to modify proper shipping names by adding one or more words to the PSN. It’s these extra words that can, sometimes, cause problems when omitted. And replacement of one of these modified PSNs by its identification number for purposes of e-transmission can cause such an omission when the PSN is reconstituted at the other end.
MIXTURE or SOLUTION: If a nail polish remover is 95% acetone with a few innocuous additives like pink color and rose scent, its transport classification will be UN1090, Acetone Solution (or Acetone Mixture), 3, II. If this is abbreviated to just UN1090 and reconstituted later, the PSN becomes merely Acetone. So, what? If this stuff spills and the emergency response team sees just Acetone as the PSN on the shipping document, they will expect to see a colorless, transparent liquid that smells like, well, acetone. But if they see pink liquid, and if they smell roses, they’re likely to question the accuracy of the transport classification. And if the PSN is possibly wrong, the emergency responders will wonder if the primary hazard is wrong, too.
I assure you that responding to a spill of an unknown chemical that might have a variety of hazards is much more difficult and time-consuming than responding to a well-characterized, single hazard, flammable liquid spill. So, keeping the “solution” or “mixture” as part of the PSN is crucial, because it tells the emergency responders that even though it doesn’t look or smell like acetone, if they treat it as Acetone they’ll be taking the appropriate response measures.
STABILIZED: If a material might either decompose or polymerize dangerously when not stabilized, that material is forbidden from transport. But when that materials has been stabilized, by any of a variety of methods such as blanketing, addition of inhibitors, or temperature control, it is no longer forbidden. If such a material has any other hazard, it is classified per that hazard, and “stabilized” is added to the PSN. For example, it is possible to have a UN3082, Environmentally Hazardous Substance, Liquid, n.o.s. (appropriate technical name), 9, III. When abbreviating this classification as ‘UN3082’ or even as ‘UN3082 (appropriate technical name)’ and later reconstituting, the “stabilized” is almost certainly lost. As events on the MSC Flaminia showed us, chemical inhibitors don’t last forever, and prolonged exposure to warmth might shorten that duration. We’ll never know for sure, but wouldn’t it have been nice for the crew of the Flaminia to know the material was “stabilized”, so perhaps they could have treated it differently and prevented the subsequent, deadly, disaster?
RESIDUE LAST CONTAINED or variants thereof: To be sure, this addition to a PSN isn’t always strictly an addition to the PSN itself, but sometimes an additional description element to a full shipping paper description, and in some cases, might be optional. But it might be important for transporters, handlers, and responders to know whether a container if full of a flammable liquid with minimal air (and thus oxygen) available, and thus not likely to ignite, or is mostly full of a mixture of flammable vapors and oxygen just ready to be set off into an explosion by a spark, static electricity charge, or spot of heat. Why spend response effort on preparing for 200 L of liquid from a ruptured drum when there’s only 5 L in it? Clearly, the additional information can be helpful, and shouldn’t be lost somewhere along the transport chain.
HOT or ELEVATED TEMPERATURE: Retained thermal energy isn’t a hazard listed in Classes 1 - 8, and didn’t use to be in Class 9 until there were some accidents and people got hurt because they didn’t know the spilled material was very, very hot. So, ETM (elevated temperature material) got added to Class 9, where it gets a PSN and identification number that warn of the high T hazard, IF that’s the only hazard. But what if something in Classes 1 – 8 is shipped at an excessively high temperature? Well, then we must add the word HOT to the PSN, unless “molten” or “elevated temperature” is already part of the PSN.
So, what happens if the identification number was used instead of the full description and the word “HOT” got lost when reconstituting the description for a non-original shipping document? Wouldn’t it be possible for a tank truck or ISO container involved in an auto accident to spill large amounts of a, say, HOT corrosive solid, onto a highway and median? Could the police officers directing traffic around the spill get too close and get thermal burns. Could the heat set the dead or dry grass in the median on fire with no one prepared to deal with that possibility? The word HOT was originally there for a good reason.
INHALATION HAZARD: This one is also technically a basic description add-on rather than just a PSN add-on, but the concept is the same. The USA requires the addition of this term when a chemical is a toxic gas or liberates large amounts of toxic gas when spilled. It doesn’t require much imagination to realize that emergency response procedures related to evacuations could differ drastically depending upon the presence or absence of these additional words. However, to be fair, I don’t think this is quite as likely to be a problem, as just “2.3” communicates the same thing, and of the 6.1 Inhalation Hazards, many are already listed by name with appropriate response measures fairly well known. But, for mixtures and for new chemicals, of which there are millions, the presence or absence of “Inhalation Hazard” from the n.o.s. description could conceivably affect many lives.
MOLTEN: The word “molten” can occasionally stand in for the word HOT, but often doesn’t mean there’s any heat (retained thermal energy) above what the atmospheric temperature is. The cutoff point for determining whether a chemical is a liquid or a solid is 20°C (68°F), so anything that melts above that temperature is a solid by definition. But, we do know that ambient temperature during transport can get up to (and sometimes over) 55°C (131°F). So, any material with a melting point above 20C but below 55C might turn into the ‘liquid phase’ during transportation, even though it’s a solid by definition and PSN. How do we let people know that a ruptured container of a “solid” may not just fall out into a stationary pile like a normal solid, but might actually flow away, a long ways away, from the container itself because it is a solid in a liquid state? We require the addition of the word “molten” to the PSN. Conceivably, losing the “molten” during e-transmission of DG info from one party to another could cause someone to not adequately contain a spilled ‘solid’, which could then cause additional, unnecessary problems.
So far we have six examples of potential or actual problems that could be or have been caused by omitting the PSN modifiers after e-transmission of DG data. There are others, although I don’t think they’re as much a safety as an environmental risk; Marine Pollutant, the USA’s RQ (hazardous substance), and the word “WASTE”. Nonetheless, even if omitting them generates a lesser level of concern, omitting them when they’re required is non-compliant, and could conceivably damage our environment.
We have a great system for helping reduce dependence on any one specific language, and using identification numbers matched to Proper Shipping Names is quite effective the vast majority of the time. But, as we move more and more to electronic or virtual shipping documents, we risk the unintended consequences of losing important safety information if we’re not very, very careful. As the investigation into the Flaminia disaster showed us, we’ve already got electronic communication systems that have this problem, so it’s actual, not theoretical.
In my opinion, from my Porch Swing, I think we need to ensure DG experts during training have these ‘add-ons’ emphasized more than they’ve been mentioned in the past, and then the DG experts will know to be sure to have the computer programmers take them into account. And wow, isn’t that a lot of people affected? Count up all the trainers and training program creators, add the number of DG experts in the world with or without a certification or DGSA, and then top it off with everyone who has input into how e-shipping papers should and will work, and you’ll have what I believe is a large number. So, fixing this will likely involve a significant amount of effort. And it’s all due to an unexpected, unintended consequence of a fantastically helpful system that helps us be (mostly) language-independent.
This is the latest in a series of musings from the porch swing of Gene Sanders, principal of Tampa-based WE Train Consulting and chair of the Dangerous Goods Trainers Association; telephone: (+1 813) 855 3855; email firstname.lastname@example.org.
[post_title] => View from the Porch Swing: Unintended consequences
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[post_name] => view-from-the-porch-swing-unintended-consequences
[post_modified] => 2018-09-18 07:56:38
[post_modified_gmt] => 2018-09-18 06:56:38
[post_parent] => 0
[guid] => https://www.hcblive.com/?p=10111
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View from the Porch Swing: Unintended consequences